The following examples of indications are intended to be a starting point for consideration of whether a transaction or order2 is suspicious. They are neither conclusive nor comprehensive.

Possible Signals of Insider Dealing

2.

A client opens an account and immediately gives an order to conduct a significant transaction or, in the case of a wholesale client, an unexpectedly large or unusual order, in a particular security - especially if the client is insistent that the order is carried out very urgently or must be conducted before a particular time specified by the client.

3.

A transaction or order2 is significantly out of line with the client's previous investment behaviour (e.g. type of security; amount invested; size of order; time security held).

4.

A client specifically requests immediate execution of an order regardless of the price at which the order would be executed (assuming more than a mere placing of 'at market' order by the client).

5.

There is unusual trading in the shares of a company before the announcement of price sensitive information relating to the company.

6.

An employee's own account transaction is timed just before clients' transactions and related orders in the same financial instrument.